It depends. If it's a bed with very tight flowers that are replanted every year, I prefer sprays with 12" heads. When it is a bed with shrubs, bushes, trees, tall ornamental grasses, I prefer drip.
One thing to consider. With the water restrictions we have here of two days a week watering with traditional overhead watering, there are NO restrictions for drip. So drip zones for trees/shrubs/etc, can water more than two days a week if needed. Even subsurface drip for turf is non-restricted.